United States District Court
District of the Southwest Desert
Civil Division
Civil Division
FIRST AMENDED COMPLAINT
FOR PRODUCT LIABILITY, NEGLIGENCE,
AND BREACH OF WARRANTY
FOR PRODUCT LIABILITY, NEGLIGENCE,
AND BREACH OF WARRANTY
Case No. 2:26-cv-00732-WEA
Filed: January 15, 2026
Filed: January 15, 2026
WILE E. COYOTE
An individual residing at
Cave No. 7, Mesquite Flat,
Sonoran Desert, Arizona
Plaintiff,
An individual residing at
Cave No. 7, Mesquite Flat,
Sonoran Desert, Arizona
Plaintiff,
v.
ACME CORPORATION
A Delaware corporation
with its principal place of business at
1 Anvil Plaza, Industry City, CA 91789
Defendant.
A Delaware corporation
with its principal place of business at
1 Anvil Plaza, Industry City, CA 91789
Defendant.
I. Nature of the Action
1. This action arises from Defendant ACME Corporation's systematic design, manufacture, distribution, and sale of defective products that have caused Plaintiff Wile E. Coyote catastrophic physical injury, severe emotional distress, and substantial economic harm over a period spanning multiple decades.
2. Defendant has maintained market dominance in the cartoon physics sector through aggressive marketing while knowingly distributing products with failure rates that would be considered unacceptable in any legitimate industry. Plaintiff, having been Defendant's most loyal customer, has been the primary victim of this corporate malfeasance.
EXHIBIT A
Plaintiff Wile E. Coyote and Legal Representation
Filed: January 15, 2026 | Case No. 2:26-cv-00732-WEA
Filed: January 15, 2026 | Case No. 2:26-cv-00732-WEA
II. Factual Background
3. Plaintiff, a self-educated genius specializing in advanced physics and mechanical engineering, has devoted his professional life to the pursuit of food acquisition, specifically the capture of a particular roadrunner (Geococcyx californianus) whose superior speed has necessitated Plaintiff's reliance on technological assistance.
4. Beginning in approximately 1949 and continuing through the present date, Plaintiff has purchased products exclusively from Defendant's catalog, which Defendant represents offers "Quality Products for the Discerning Predator." Plaintiff has retained all receipts, catalogs, and correspondence with Defendant, comprising over 10,000 individual transactions totaling in excess of $4,200,000 in purchases.
5. Despite Defendant's express warranties and implied warranties of merchantability and fitness for a particular purpose, virtually every product Plaintiff purchased from Defendant has failed catastrophically during normal and intended use. These failures have resulted in injuries including but not limited to: concussions (437 documented), fractures (892), burns of varying degrees (1,247), compression injuries from falling objects (3,412), and psychological trauma that medical experts have described as "unprecedented in the annals of consumer protection."
III. Specific Product Failures
6. Plaintiff incorporates by reference the following documented product categories, each representing systematic design and manufacturing defects:
EXHIBIT B: Catalog of Defective Products
| Category | Products | Documented Failures | Injury Classification |
|---|---|---|---|
| Explosive Devices | Bombs, Dynamite, TNT, Detonators | 2,347 | Severe |
| Magnetic Apparatus | Industrial Magnets, Electromagnetic Devices | 423 | Moderate-Severe |
| Heavy Falling Objects | Anvils, Boulders, Pianos, Safes | 1,892 | Severe |
| Propulsion Systems | Rockets, Jet Skates, Rocket-Powered Unicycles | 876 | Critical |
| Transport Devices | Steamrollers, Trains, Tunneling Equipment | 234 | Severe |
| Spring Mechanisms | Compression Springs, Coils, Launch Devices | 567 | Moderate |
| Disguises & Deception | Bat Suits, Invisible Paint, Costumes | 198 | Moderate-Severe |
| Pharmaceuticals | Earthquake Pills, Speed Formulas | 156 | Severe |
| Elastic Devices | Giant Rubber Bands, Bungee Cords | 342 | Severe |
IV. Legal Representation
7. The parties to this action are represented as follows:
FOR THE PLAINTIFF:
WILE E. COYOTE
Plaintiff, appearing pro se (with assistance of counsel)
Genius (self-taught), Graduate of Coyote University (Honors)
Primary Victim, Consumer Advocate
KEVIN AVERY, ESQ.
Avery & Associates, Personal Injury Attorneys
742 Billboard Boulevard, Phoenix, AZ 85001
Bar No. AZ-2026-45892
Lead Counsel for Plaintiff
WILL FORTE (Legal Consultant)
Specialist in Consumer Protection Law
Former Billboard Accident Attorney
Of Counsel
WILE E. COYOTE
Plaintiff, appearing pro se (with assistance of counsel)
Genius (self-taught), Graduate of Coyote University (Honors)
Primary Victim, Consumer Advocate
KEVIN AVERY, ESQ.
Avery & Associates, Personal Injury Attorneys
742 Billboard Boulevard, Phoenix, AZ 85001
Bar No. AZ-2026-45892
Lead Counsel for Plaintiff
WILL FORTE (Legal Consultant)
Specialist in Consumer Protection Law
Former Billboard Accident Attorney
Of Counsel
FOR THE DEFENDANT:
ACME CORPORATION
A Delaware Corporation
BUDDY CRANE, ESQ.
Partner, Crane, Crane & Anvil, LLP
1 Corporate Plaza, Suite 4000
Industry City, CA 91789
Bar No. CA-2026-12734
Lead Counsel for Defendant
JOHN CENA (Corporate Representative)
Chief Risk Management Officer
ACME Corporation
ACME CORPORATION
A Delaware Corporation
BUDDY CRANE, ESQ.
Partner, Crane, Crane & Anvil, LLP
1 Corporate Plaza, Suite 4000
Industry City, CA 91789
Bar No. CA-2026-12734
Lead Counsel for Defendant
JOHN CENA (Corporate Representative)
Chief Risk Management Officer
ACME Corporation
ADDITIONAL PARTIES AND WITNESSES:
LANA CONDOR
Forensic Product Analyst
Expert Witness for Plaintiff
TONE BELL
Expert in Coyote Physiology
Medical Expert for Plaintiff
THE ROADRUNNER (Geococcyx californianus)
Material Witness
Status: Unserved. Multiple attempts at service of subpoena have been unsuccessful due to the witness's remarkable speed.
LANA CONDOR
Forensic Product Analyst
Expert Witness for Plaintiff
TONE BELL
Expert in Coyote Physiology
Medical Expert for Plaintiff
THE ROADRUNNER (Geococcyx californianus)
Material Witness
Status: Unserved. Multiple attempts at service of subpoena have been unsuccessful due to the witness's remarkable speed.
V. Claims for Relief
8. COUNT I: STRICT PRODUCT LIABILITY
Defendant's products were defective in design and manufacture, and were unreasonably dangerous to consumers, including Plaintiff. The defects existed at the time the products left Defendant's control, and the products were used in a reasonably foreseeable manner.
Defendant's products were defective in design and manufacture, and were unreasonably dangerous to consumers, including Plaintiff. The defects existed at the time the products left Defendant's control, and the products were used in a reasonably foreseeable manner.
9. COUNT II: NEGLIGENCE
Defendant owed a duty of care to Plaintiff as a consumer of its products. Defendant breached this duty by failing to adequately test products, failing to warn of known dangers, and continuing to market products with known catastrophic failure rates approaching 100%.
Defendant owed a duty of care to Plaintiff as a consumer of its products. Defendant breached this duty by failing to adequately test products, failing to warn of known dangers, and continuing to market products with known catastrophic failure rates approaching 100%.
10. COUNT III: BREACH OF EXPRESS WARRANTY
Defendant's catalog descriptions, advertising materials, and product labeling contained express warranties that the products were suitable for their advertised purposes. These warranties were false.
Defendant's catalog descriptions, advertising materials, and product labeling contained express warranties that the products were suitable for their advertised purposes. These warranties were false.
11. COUNT IV: BREACH OF IMPLIED WARRANTY
Defendant breached the implied warranty of merchantability and the implied warranty of fitness for a particular purpose. No reasonable consumer would expect an "Earthquake Pill" to create an earthquake directly beneath their own feet.
Defendant breached the implied warranty of merchantability and the implied warranty of fitness for a particular purpose. No reasonable consumer would expect an "Earthquake Pill" to create an earthquake directly beneath their own feet.
VI. Model Output Analysis
12. The following metrics were recorded during the generation of this legal document using the Qwen3.6-35B-A3B-bf16 language model:
EXHIBIT C: Computational Performance Metrics
Prompt Tokens
1,925
Prompt Speed
1,041.812
tokens/sec
Generation Tokens
4,332
Generation Speed
63.350
tokens/sec
Peak Memory
72.812
GB
VII. Computational Record
13. The following constitutes the complete computational log of this document's generation, preserved for the record:
EXHIBIT D: Full Terminal Output
Last login: Fri Apr 24 13:46:08 on ttys000 martinrivera@Martins-Mac-Studio ~ % cd ~/Documents/qwen36_35b_a3b_bf16 martinrivera@Martins-Mac-Studio qwen36_35b_a3b_bf16 % source .venv/bin/activate (qwen36_35b_a3b_bf16) martinrivera@Martins-Mac-Studio qwen36_35b_a3b_bf16 % uv run mlx_vlm.generate \ --model mlx-community/Qwen3.6-35B-A3B-bf16 \ --max-tokens 16384 \ --temperature 0.7 \ --prompt "Analyze this image from 'Coyote vs Acme' and generate a complete, self-contained HTML legal case file page..." \ --image ~/Documents/qwen36_35b_a3b_bf16/images/coyote-vs-acme-poster.jpg ========== Files: ['/Users/martinrivera/Documents/qwen36_35b_a3b_bf16/images/coyote-vs-acme-poster.jpg'] Prompt: 1925 tokens, 1041.812 tokens-per-sec Generation: 4332 tokens, 63.350 tokens-per-sec Peak memory: 72.812 GB (qwen36_35b_a3b_bf16) martinrivera@Martins-Mac-Studio ~ %
VIII. Prayer for Relief
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment against Defendant as follows:
A. Compensatory damages in an amount to be proven at trial for all physical injuries, emotional distress, and economic losses;
B. Punitive damages to deter Defendant from continuing to market products that have a documented failure rate of 99.7%;
C. Medical expenses for all past, present, and future treatment of injuries sustained from Defendant's products;
D. Restitution of all monies paid to Defendant for defective products, estimated at $4,200,000;
E. Injunctive relief requiring Defendant to include adequate safety warnings, testing protocols, and instructions with all products;
F. Attorney's fees and costs of this action; and
G. Such other and further relief as this Court deems just and proper.
B. Punitive damages to deter Defendant from continuing to market products that have a documented failure rate of 99.7%;
C. Medical expenses for all past, present, and future treatment of injuries sustained from Defendant's products;
D. Restitution of all monies paid to Defendant for defective products, estimated at $4,200,000;
E. Injunctive relief requiring Defendant to include adequate safety warnings, testing protocols, and instructions with all products;
F. Attorney's fees and costs of this action; and
G. Such other and further relief as this Court deems just and proper.
DATED this 15th day of January, 2026.
Respectfully submitted,
Wile E. Coyote
WILE E. COYOTEPlaintiff, In Pro Per (with assistance of counsel)
Kevin Avery
KEVIN AVERY, ESQ.Avery & Associates
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that on January 15, 2026, a true and correct copy of the foregoing First Amended Complaint was served via courier upon Defendant's counsel of record at:
Buddy Crane, Esq.
Crane, Crane & Anvil, LLP
1 Corporate Plaza, Suite 4000
Industry City, CA 91789
Service upon the Roadrunner remains pending. Multiple couriers have been dispatched. None have returned.
I hereby certify that on January 15, 2026, a true and correct copy of the foregoing First Amended Complaint was served via courier upon Defendant's counsel of record at:
Buddy Crane, Esq.
Crane, Crane & Anvil, LLP
1 Corporate Plaza, Suite 4000
Industry City, CA 91789
Service upon the Roadrunner remains pending. Multiple couriers have been dispatched. None have returned.
Document generated using Qwen3.6-35B-A3B-bf16 language model
United States District Court, District of the Southwest Desert
Case No. 2:26-cv-00732-WEA | Filed January 15, 2026
United States District Court, District of the Southwest Desert
Case No. 2:26-cv-00732-WEA | Filed January 15, 2026